Judicially Noticeable Fact – Trace Your Case

ONKAR NATH & ORS V. THE DELHI ADMINISTRATION

Onkar Nath & Ors. v. The Delhi Administration AIR 1977 SC 1108

Whether the lower courts were justified in considering specific facts without needing formal evidence?

Under Section 57 of the Evidence Act, courts can take judicial notice of widely known facts without requiring formal proof.
This allows the judicial system to recognize and rely on facts of public knowledge—such as notable events—without evidence, thereby ensuring efficiency and preventing undue formalism in the judicial process.

The appellants were leaders of the Northern Railwaymen’s Union, and on May 5, 1974, a speech was made at a meeting, inciting workers to go on strike from May 8th.
Under Rule 118(1) of Defense of India Rules, 1971, the Central Government had previously issued an order on November 26, 1973, prohibiting strikes connected to industrial disputes within railway services. This prohibition aimed to maintain essential supplies and services for public welfare.
The government accused the appellants of violating this rule by inciting a strike tied to an industrial dispute.
They were convicted by the learned Metropolitan Magistrate and sentenced to six months of rigorous imprisonment.
The order of conviction was upheld in appeal by the sessions court, but in revision, the Delhi High Court reduced the sentence to the period already undergone.
On appeal to this Court, the appellants contended that the courts below were not justified in taking judicial notice that on the date they delivered their speeches, a railway strike was ready to take place, but such a strike was launched on May 8th, 1974.

The Delhi High Court ruled that as the statute of limitations automatically renews with each succeeding default, it is immaterial to determine whether the statute of limitations should be computed from the date of repudiation because the application is timely and can be brought to arbitration.
The court decided that the arbitrator might address any limitations within a specific area of the claim. The court determined that there was no legislative necessity to present the agreement to the general body of the corporation and that the directors revealed their interests and acted within the parameters of the Articles of Association.
Therefore, Section 299 was not violated. There is no Section 294 mandate to bring this to a general body meeting of shareholders because the arrangement does not establish an agreement to name a sole selling agent.
The fundamental query is whether the directors’ behaviour passes muster in light of their fiduciary duty to the corporation.
The Court determined that the provisions of the agreement from June 1, 1967 were bad for the company and that the directors used them for their own gain without completing any work.
As a result, the agreement is null and void, and the appellants are entitled to the recession remedy. Directors have a responsibility to put their best efforts into serving the interests of those who have entrusted them with that responsibility, and they are required to put those interests ahead of their own if doing so would be improper.